The Centers for Medicare and Medicaid Services (CMS) has released two long awaited proposed rules: the 2020 Physician Fee Schedule (PFS) and the 2020 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System. ACEP provided extensive commentary on these proposed rules, and CMS is expected to finalize these provisions by early November 2019. Overall, CMS has recognized that emergency medicine is providing higher-intensity care and, as a result, our work relative value units (RVUs) will be increasing.

You can read ACEP-submitted commentary on the proposed PFS rule.

2020 Conversion Factor Increase

For 2020, CMS proposes a Medicare PFS conversion factor of $36.0896 representing a small increase from the 2019 conversion factor of $36.0391. Note that the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) provided 0.5% base updates to the conversion factor through 2019. Those base updates have now expired, leading to this relatively smaller increase.

2020 RVUs Increase for ED E/M Services

Each year, RVU values for physician services are updated. This year, CMS had concerns that the emergency department evaluation and management (E/M) Current Procedural Terminology (CPT) codes were undervalued and requested that the American Medical Association’s Relative Value Update Committee (RUC) perform a survey and revalue the work RVUs associated with the relevant codes.

“In the CY 2018 PFS final rule, we finalized a proposal to nominate CPT codes 99281–99285 as potentially misvalued based on information suggesting that the work RVUs for emergency department visits may not appropriately reflect the full resources involved in furnishing these services (FR 82 53018).”—2019 Physician Proposed Rule, page 420

ACEP undertook an extensive survey process and mounted compelling arguments describing the increased complexity of the patients we treat every day in the nation’s emergency departments. (Read more about ACEP’s efforts to increase emergency physicians’ reimbursement rates at ACEP4U.) In good news for emergency medicine, CMS has proposed to revalue the codes based on the RUC recommended work values (see Table 1). (To read behind-the-scenes information about how our ACEP volunteers and staff formed the winning arguments, read our previous ACEP4U article from the September 2019 issue.)

Table 1: 2020 Proposed Increases to ED Work RVUs

A more detailed fact sheet on the 2020 PFS payment proposals.

Merit-Based Incentive Payment System

The Merit-Based Incentive Payment System (MIPS) is a payment mechanism that provides for annual reimbursement adjustments related to CMS quality program requirements in four categories: quality, cost, promoting interoperability, and clinical practice improvement activities. For the 2020 performance year (affecting 2022 payments), the relevant MIPS categories for typical emergency medicine groups will include (see Figure 1):